Privacy Policy

Please read our Privacy Policy which is applicable when your browse the Site, regardless of whether you decide to use the services and/or purchase any products. We also recommend you read the Site's General User Conditions as they provide information on Privacy and the security systems adopted by the Site.

The processing of Personal Data of website users will be performed in Italy and conducted in accordance with applicable European legislation and the Personal Data Protection Code (Legislative Decree 30 June 2003, No. 196), which governs the processing of personal data by anyone who resides or has a registered office in Italy. Triboo Digitale S.r.l., with registered office in Milan (Italy), viale Sarca 336, edificio 16, Post Code 20126, tax code, VAT number and Milan Business Register number 02912880966 ("Triboo Digitale"), provides e-commerce services and the sale of products via the Site, in its capacity as joint Data Controller together with Thun S.p.A., Via Galvani, 29 - 39100 Bolzano, Italia.

1. THE POLICY

All Data subjects are entitled to the protection of their Personal Data. Triboo Digitale and Thun S.p.A. respects the rights of its users to be informed on the collection and subsequent processing operations concerning their Personal Data. We always try to respect a strictly necessary principle when processing data that can identify you, even indirectly. For this reason, we have configured the Site so that the use of personal data is kept to the minimum necessary and exclude the processing of personal data when the purpose of the specific activity can be achieved using anonymous data or other means, identifying the person only when needed or at the request of the authorities and police forces. This Privacy Policy will provide all useful information to understand how we collect and use the information that identifies users on the Site . For further information on our Privacy Policy please send an e-mail to www.garanteprivacy.it or to Triboo Digitale at the addresses shown above.

2. WHO PROCESSES YOUR PERSONAL DATA, HOW AND FOR WHAT PURPOSES

Triboo Digitale is the Data Controller of the Personal Data of Thun users, with the purpose of managing, finalising and implementing sales transactions concerning the purchase of products via the same Site ("Purpose"), Triboo Digitale decides the purposes and methods used to process such data and the instruments to be used, including all security related aspects. For purely organisational and functional requirements, we have appointed some Chief Processors to manage user Personal Data, for purposes strictly linked and related to the provision of services on the Site, including the sale of products. Such Chief Data Processors have been selected on account of their experience, capabilities and reliability, thorough compliance with the provisions in force applying to processing as also related to security matters. Therefore, the Data Controller, with reference to any additional activities, also non functional to the sale of products through the Site (for example and not limitedly to, products delivery, handling of returns and claims, transmission of advertising materials on products and services other than those potentially purchased on our website) is exclusively Thun S.p.A.. Prior explicit and specific authorisation of the concerned party, the personal data collected through the Site will also be processed in order to be transmitted by Thun S.p.A to partner companies for their promotional initiatives and in order for the latter to send their promotional communications on products and services. Thun S.p.A.’s partner firms belong to the so called “large-sale retail sector” or the following product categories: clothing, publishing, electronics and computers, finance and insurances, tourism and accommodation providers, grocery, couponing, cosmetics, pharmaceutical and giftware. Chief Processors process the Personal Data of Site users following the instructions provided by Triboo Digitale.

Please contact the Customer Care service for a complete list of the Chief Processors assigned to processing your Personal Data, or send an e-mail to: privacy@thun.it for Thun S.pa.; privacy@triboo.it for Triboo S.pa..

In particular, to achieve our Purposes, and as part of the process when purchasing products on the Site,we collect Personal Data (e.g. name and surname, e-mail address, mailing address, credit card and bank details, telephone number) via the product order form available on the Site.

Personal Data are mainly processed in electronic format and in certain cases also in paper format, such as for instance, when the processing of personal data is necessary to prevent fraud on the Site.

Personal Data shall be retained in the form that allows you to be identified for the time strictly necessary for the purpose for which the data were collected and subsequently processed and, in any case within the limits foreseen by the laws in force. To ensure that Personal Data is always accurate and updated, pertinent and complete, you are asked to kindly notify us of any changes to the same sending us an e-mail to: privacy@triboo.it.

Further to what already provided for above, Personal data shall not be disclosed to third parties for purposes not permitted by law or without your express consent.

Personal data is made available to third parties, for ancillary purposes related to the provision of services required by the user (for example, for purchase related transactions). For further details on this aspect, please consult paragraph 4 (Whom we disclose Personal Data to). You can at any time obtain an updated list of Chief Data Processors by sending a request to the following e-mail address: privacy@triboo.it.

Your personal data can be disclosed to Police forces or Judicial authorities, for instance pursuant to Site anti-fraud services, in accordance with the laws in force and whenever requested. Your Personal Data will also be accessible to Chief Data Processors as indicated in paragraph 2 and for the specific purposes listed therein. Personal data will not be transferred abroad to Countries other than those belonging to the European Union, which do not guarantee a sufficient level of privacy protection. If the above should be necessary to achieve our Purposes, we will ensure that the transfer of Personal Data to Countries which do not belong to the European Union and do not guarantee adequate levels of protection, will only be implemented after such parties and Triboo Digitale have all signed specific contracts containing clauses for the protection of Personal Data, in accordance with applicable law and regulations.

The purposes for which your Personal Data are processed shall be specifically disclosed each time in the Information Note text provided on the page where the same are requested to confer their Personal Data.

There may be cases where Triboo Digitale processes third-party personal data communicated directly by Triboo Digitale users, e.g. when the user intends to tell a friend about a service or product on sale at the Site, or when the user purchases a product to be sent to a friend or when the subject paying for the purchase is different to the subject to whom it will be delivered.

In such cases, you are required to be sure to obtain the consent of the person in question before conferring their data to Triboo Digitale, and to inform about this Privacy Policy because you will, in fact, be the only person responsible for the conferral of third party information and data without specific request or consent of the same, further to any misuse or illegal use of the same. In any case, Triboo Digitale, to the extent required by law, shall fulfil its disclosure obligations to the indicated user and, where necessary, request relative consent, upon registration of the relevant data in its Personal Data archives.

3. DENYING CONFERRAL OF PERSONAL DATA AND RELATIVE CONSEQUENCES

Conferment of personal data to Joint Data Controllers and in particular name, email address, mailing address, credit/debit card and bank details and telephone number is required to attain the aforementioned scopes.

Some of the aforementioned data may be indispensable so as to fulfil the obligations imposed by the law or other regulations, or to provide other services you may have requested as provided on the Site.

Refusal to disclose certain essential Personal Data, identified on the Site by an asterisk (*), may make it impossible to complete all purchase contract phases, and/or fulfil all obligations required by the laws and regulations in force. Failure to disclose certain Data can therefore, according to individual circumstances, constitute a legitimate and justified reason preventing the execution of the purchase contract on the Site or the supply of services via the same.

On the other hand, conferral to Triboo Digitale of additional Personal Data, other than those which are compulsory, is optional and has no impact on the purchase of products on the Site.

4. TO WHOM WE DISCLOSE YOUR PERSONAL DATA

Personal Data may be disclosed and made available to third party companies that provide specific services to Thun S.p.a. and/or Triboo Digitale, as Chief Data Processors or disclosed to other recipients of the data collected by Thun S.p.a. and/or Triboo Digitale, who process data independently for the sole purpose of executing the purchase contract for products on the Site (such as, for instance, Global Collect, for the execution of remote electronic payment services, via credit card/debit card) and only when such a purpose is not inconsistent with the purposes for which your Personal Data was collected and subsequently processed and, in any case, in full compliance with the laws in force.

No Personal Data shall be disclosed, assigned or otherwise transferred to third parties without informing users and obtaining their consent in advance, when required by law.

5. HOW WE COLLECT YOUR ON THE SITE

Triboo Digitale collects Personal Data and other information during the online registration process or when sending order forms to purchase products on the Site so as to execute e-commerce transactions. These data are processed by Triboo Digitale within the limits and purposes illustrated in the Information Note presented to users in the relative data collection section.

6. SECURITY MEASURES

We have taken all suitable security measures to minimise the risk of destruction or loss, even accidental, of such Data, further to unauthorised access or processing that is not authorised or does not comply with the scope and purpose of collection indicated in our Privacy Policy.

However, as it is impossible to guarantee that such measures for the security of the Site and the transmission of data and information on the same Site limit or exclude any risk of unauthorised access or dissemination of data, we recommend you check that you have an updated antivirus protection system installed on your computer, which protect incoming and outgoing data, and that your Internet provider uses firewalls and anti-spamming filters where suitable for the security of data transmission on the web.

7. RIGHTS TO ACCESS PERSONAL DATA AND OTHER RIGHTS

You are always entitled to receive confirmation as to whether or not Personal Data concerning you exists, regardless of their being already recorded, and communication of such data in an intelligible form.

You are also entitled to receive information concerning the origin of the Personal Data; the purpose and processing methods; the logic used in the case where the data is processed using electronic equipment; the personal data of the Data Controllers, information on the subjects or categories of subjects to whom the personal data may be disclosed or who may become aware of such data in their capacity, for instance, as Chief Processors or Designated Officers. Part of this information is contained in our Privacy Policy; if you wish to receive further details, please send an e-mail to privacy@triboo.it.

- erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;

- certification to the effect that the operations indicated above have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared to the right that is to be protected.

You are also entitled to oppose, totally or partially:

- for legitimate reasons, the processing of your personal data, despite them being relevant to the purpose of the collection;

- to the processing of Personal Data concerning you, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

- You are entitled to exercise your rights at any moment in time, within the terms and conditions of the law, sending such requests by e-mail to Triboo Digitale at privacy@triboo.it.; we will respond to your mail as soon as possible.

8. LINKS TO OTHER WEBSITES

Triboo Digitale does not control or monitor the operations of such websites or their content. Triboo Digitale shall not be held liable for the web content of such sites or the rules adopted by the same regarding your privacy and the processing of your Personal Data whilst browsing their website. Please therefore pay attention when you access these websites via the links on our website and remember to read their terms and conditions of use and privacy policy carefully. The Privacy Policy adopted by Site does not apply to third party websites and Triboo Digitale is under no circumstances liable for the privacy policy applied by those websites.

The Site provides links to these websites exclusively to assist users in their search and browsing activities and to facilitate links to other websites on the Internet. Posting of such links does not infer that Triboo Digitale recommends the use or browsing of these websites, nor any guarantee of their content, services or merchandise supplied and sold to Internet users.

9. CONTACTS

If you wish to receive further information on how Triboo Digitale and Thun S.p.A. processes Personal Data, please send an e-mail to the following email address: privacy@thun.it for Thun S.p.A.; privacy@triboo.it for Triboo Digitale. To receive further information and be updated on the rights and the regulations concerning the protection of persons in relation to the processing of Personal Data, please visit the website of the Authority for the Protection of Personal Data at www.garanteprivacy.it

10. APPLICABLE LAW

This Privacy Policy is governed by Italian law and in particular by the Data Protection Code (Legislative Decree No. 196 of June 30, 2003) which governs the processing of personal data – including those retained overseas - carried out by anyone who is resident or located in Italy or using instruments located in Italy.

The Code ensures that Personal Data are processed by respecting data subjects’ rights, fundamental freedoms and dignity, particularly with regard to confidentiality, personal identity and the right to Personal Data protection.

11. CHANGES AND UPDATES TO THE PRIVACY POLICY

Triboo Digitale may amend or simply update all or part of the Site Privacy Policy also when amendments are made to laws or regulations that govern protection of personal data and your rights. Changes and updates to the Site Privacy Policy will be notified to users on the Homepage of the Site as soon as the same are adopted and shall be binding once posted on the website in this section. We therefore recommend you access this section regularly in order to check the most recent and updated version of the Site Privacy Policy.

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